Andrew Heisey - Page 3




                                        - 3 -                                         
               Petitioner received $72,821, $54,086.38, and $57,575.69 in             
          wages from Contract Services Co. during 1996, 1997, and 1998,               
          respectively.  Federal income tax of $3,071.14 was withheld from            
          petitioner’s wages from Contract Services Co. in 1998; no Federal           
          income taxes were withheld in 1996 and 1997.  Petitioner received           
          $9,410 and $17,740 in nonemployee compensation from Acorn Product           
          Development, Inc., during 1997 and 1998, respectively.  On                  
          December 9, 1998, petitioner sold a single family residence                 
          located at 2716 Morrene Drive, Placerville, 95667 for $112,500.             
          Petitioner was the owner of this property immediately prior to              
          its sale.                                                                   
               Petitioner did not file Federal income tax returns for 1996,           
          1997, or 1998.  Respondent issued a notice of deficiency to                 
          petitioner, and petitioner filed a petition with this Court.                
                                       OPINION                                        
          A. Income Tax Deficiencies                                                  
               Section 61(a)1 includes within the definition of gross                 
          income, “all income from whatever source derived” including                 
          compensation for services and gains derived from dealings in                
          property.  See United States v. Connor, 898 F.2d 942, 943 (3d               





               1Unless otherwise indicated, all section references are to             
          the Internal Revenue Code in effect for the tax years in issue,             
          and all Rule references are to the Tax Court Rules of Practice              
          and Procedure.                                                              




Page:  Previous  1  2  3  4  5  6  7  8  Next

Last modified: May 25, 2011